As a dealer, your duty to record mileage goes beyond just completing the odometer disclosure at the time of sale. You must record the mileage of every vehicle when you acquire it and when you dispose of it. This creates a chain of mileage documentation that allows anyone — a subsequent buyer, a regulatory agency, a court — to trace the vehicle’s mileage history through your dealership.
When you purchase a vehicle — whether from a private party, at auction, from another dealer, or through a trade-in — record the odometer reading on the title, on the odometer disclosure statement, and in your own internal records. When you sell the vehicle, record the odometer reading again. Compare the reading at acquisition with the reading at sale. The reading at sale should be higher than the reading at acquisition, reflecting any miles you or your employees put on the vehicle while it was in your inventory — test drives, lot movements, reconditioning trips, and so on.
If the odometer reading at sale is lower than the reading at acquisition, that’s a red flag that requires investigation. Did the odometer malfunction? Was there a recording error? Was the odometer tampered with? You need to determine the cause and document it. If the discrepancy can’t be explained, you may need to disclose the mileage as “not actual” or “odometer discrepancy” on your disclosure statement.